Chemical Data Reporting Quick Reference Guide Create a Primary Form U

CDXr

Chemical Data Reporting Quick Reference Guide

Create a Primary Form U

Quick Reference Guide
Creating a Primary Form U

Prerequisites

1. User is registered in CDX and has a role as either an Authorized Official or Agent/Consultant in the
Chemical Data Reporting application.

2. See the User Roles and Access Quick Reference Guide for details.

Creating a Primary Form

* asterisks mark required fields

An © icon next to a field provides additional information about the field. To activate the legend place the mouse cursor over
the icon and a brief explanation will display. This tooltip does not provide navigation.

1. Log in to CDX at https://cdx.epa.gov/.

2. Click the Primary Authorized Official or Primary Agent/Consultant link.

3. Select TSCA Chemical Data Reporting 2020 from the drop-down on the Chemical Information
Submission System page.

4. Click the OK button.

5. Click the Create New Form button within the Actions column for the desired site on the Manage
Forms page.

6. Create a Passphrase to secure access to your form. Enter the following information on the Create
Passphrase page:

a. New Passphrase *

b. Confirm Passphrase *

i. The passphrase must be between 8 and 20 characters long and may not contain special
characters (+,?,*, etc.)

c. After creating a passphrase, add a Passphrase Hint to help you remember the passphrase for this
form. If you forget the passphrase, after three (3) failed attempts the hint will display. Please do
not include the passphrase as part of your hint *

7. Click the Continue button.

Accessing an Existing Primary Form

1. Log in to CDX at https://cdx.epa.gov/.

2. Click the Primary Authorized Official or Primary Agent/Consultant link.

3. Select TSCA Chemical Data Reporting (CDR) 2020 from the drop-down on the Chemical
Information Submission System page.

4. Click the Edit icon within the Actions column for the desired site on the Manage Forms page.

5. Enter the passphrase on the Enter Passphrase page.

6. Click the Continue button.

7. If you fail to provide the correct passphrase 3 times, the Hint entered in Creating a Primary Form step
6.c above will display.

8. If you are still unable to access the form, then click the Reset Passphrase link to generate and send an
email with a temporary passphrase to the appropriate individuals (i.e., Authorized Official who created
the passphrase and approved Authorized Official(s), Primary and Secondary Agent/Consultant) of the
passphrase change request.

0 EPA TO 47QFCA-18-F-0009

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CDXr

Chemical Data Reporting Quick Reference Guide

Create a Primary Form U

Step 1 Form Information

*asterisks mark required fields

Step 1.1 Identify a Highest-level Parent Company

Step 1.1.1 User Registered in CDX with a U.S. Company Identify

1. Verify or update your highest-level U.S. parent company information

a. The information you entered upon registering in CDX is used to pre-fill in the U.S. company
identity. Verify that the information displayed on the Parent Company Information page
correctly identifies the highest-level parent company for the site or update as needed and
populate the following fields:

Company Name *

ii.

Company Dun & Bradstreet Number *

iii.

Company Address *

iv.

Company Address 2

City*

vi.

County/Parish *

vii.

State/Province/Other *

viii.

Zip Code *

ix.

Country * (displays United States)

b. Click the Save button.

c. Click the Cancel button to close the parent company fields without saving the entered
information.

2. Add your Highest-level Foreign Parent Company

a. Click the Add Foreign Parent Company button to report a foreign organization as your
highest-level foreign parent company for the site. Otherwise, to continue without a foreign parent
company, proceed to step 10.

b. Populate the following fields to identify the foreign parent company.

Company Name *

ii.

Company Dun & Bradstreet Number *

iii.

Company Address *

iv.

Company Address 2

City*

vi.

County/Parish

vii.

State/Province/Other

viii.

Zip Code *

ix.

Country *

c. Click the Save button.

3. Modify your Highest-level U.S. or Foreign Parent Company

a. Click the Edit icon within the Actions column to modify the U.S. or foreign parent company
information.

b. Click the Delete icon within the Actions columns to remove a U.S. or foreign parent company.

c. Click the Continue button.

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Chemical Data Reporting Quick Reference Guide

Create a Primary Form U

Step 1.1.2 User Registered in CDX with a Non-U.S. Company

1. Verify or update your highest-level foreign parent company information

a. The information you entered upon registering in CDX is used to pre-fill in the foreign company
identity. Verify that the information displayed on the Parent Company Information page
correctly identifies the highest-level foreign parent company for the site or update as needed.

b. Add the Dun and Bradstreet Number for your organization.

c. Click the Save button.

2. Add your highest-level U.S. parent company information

a. Click the Add U.S. Parent Company button.

b. Enter the required information for the highest-level U.S. parent company.

i. Company Name*

ii. Company Dun & Bradstreet Number *

iii. Company Address *

iv. City *

v. County/Parish *

vi. State/Province/Other *

vii. Zip Code *

c. Click the Save button.

3. Modify your Highest-level U.S. or Foreign Parent Company

a. Click the Edit icon within the Actions column to modify the U.S. or foreign parent company
information.

b. Click the Delete icon within the Actions columns to remove a U.S. or foreign parent company.

c. Click the Continue button.

Step 1.2 Site Information

* asterisks mark required fields

1. Verify that the Site Information data is correct.

2. Enter the Site Dun & Bradstreet Number. *

a. Dun & Bradstreet number can contain only numeric characters or dashes and is of format XX-

xxx-xxxx

3. Click the Add NAICS Code button to generate the Add NAICS Code window and provide at least one
but no more than three NAICS code(s). *

a. Select the appropriate value from the NAICS Code * dropdown menu

b. Select the activity value from the Activity Classification drop-down menu

4. Click the Add To List button to populate the entered information into the NAICS code table.

5. Click the Cancel button to close the Add NAICS Code window without saving the entered information.

a. Click the Edit icon within the Actions column to modify a NAICS code entry

b. Click the Delete icon to remove a NAICS code entry

6. Click the Continue button to proceed to Step 2 - Chemicals.

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Chemical Data Reporting Quick Reference Guide

Create a Primary Form U

Step 2 Chemicals

Chemicals can be reported in different manners depending on how the manufacturing process was conducted.

To add Chemicals to your Primary Form U, identify how you are reporting your chemicals. Refer to the

following quick reference guides (QRGs) for specific instructions:

• CDR 2020 QRG - Report a Manufactured or Imported Chemical when selecting the My site is
reporting the manufacture (including import), processing, and use of the chemical checkbox to
indicate that this site is reporting all the information for this chemical.

• CDR 2020 QRG - Report a Co-Manufactured Chemical as a Contracting Company when selecting
the My company contracted with a co-manufacturer to produce the chemical at their site, checkbox to
indicate that the manufacturing-related information will be reported by the producing company.

• CDR 2020 QRG - Report a Co-manufactured Chemical as a Producing Company when selecting
the My site is reporting the production of the chemical for another company under a co-
manufacturing contract, checkbox to indicate that this site is reporting the production information on
behalf of a contracting company under a co-manufacturing contract.

Once all the chemicals have been added to the form select the Continue button to proceed to Step 3 - CBI

Substantiation.

Step 3 CBI Substantiation

Step 3.1 Review claims for accuracy

Step 3.1.1 Substantiation Status

1. Review the Status column to determine whether the CBI claims listed require substantiation answers.

a. A grey checkmark indicates that although the chemical or trade product contains confidential
claims, these claims are exempt from substantiation and do not require further action.

b. A green checkmark indicates that all of the confidentiality claims either have the required
substantiation answers provided or are exempted from the need for substantiation.

c. A chemical without a checkmark icon indicates that some or all confidentiality claims are
incomplete and do not contain the corresponding substantiation answers. To provide the answers
to the substantiation questions individually, proceed to Step 3.1.2, To copy previously completed
substantiation answers, proceed to Step 3.1.2.1,

2. After all confidentiality claims have been substantiated as required, select the Continue button.

a. A pop-up message will display "Claims of confidentiality and, if required, substantiation of the
claims are required at the time of submission (40 CFR 711.30(a)(1)). If you need to make
additional confidentiality claims or substantiations, select the Cancel button to close this window
and update the claims as needed. If your confidentiality claims and substantiations are complete,
select the Continue button to move forward with the validation and submission of your form.
Information not claimed as confidential in accordance with the requirements of 40 CFR 711.30
may be made public without further notice to the submitter. "

b. If you are ready to submit your form, click the Continue button and proceed to Step 4.

Otherwise click the Cancel button to return to the form and submit at a later time.

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Chemical Data Reporting Quick Reference Guide

Create a Primary Form U

Step 3.1.2 Complete Substantiation Answers

1. If the chemical is missing a checkmark icon on the Status column, click the Expand (+) icon to view
the sections that contain confidential claims.

a. There are up to two indicators for each section header:

i. (#/#) indicates the number of confidential claims made out of the total number of claims
possible for that section.

ii. Checkmark icon, described in step 3.1.1, bullet 1.

b. If a section header has (0/0) listed, there are no confidential claims made in this section, and
therefore substantiation answers are not needed.

c. If a section header has (3/6) listed, it means that you claimed 3 out of a total of 6 possible data
elements as confidential data elements.

d. If a section header has a green checkmark displayed, this indicates that substantiation answers
have been provided or are not required, and this section is complete.

e. If the checkmark icon is not displayed, this indicates that substantiation answers are missing
and need to be provided.

2. Click the section header to expand the menu and see the data elements that require attention.

3. Scroll up or down to find the available links for elements claimed confidential.

4. Each element has a set of general questions with Yes or No selections and an explanation text box that
allows you to provide the corresponding answer to the question. Complete each set of questions by
selecting the appropriate radio button (Yes/No) for each question.

5. Check the corresponding CBI checkbox to claim the substantiation answer as confidential.

6. After completing all corresponding questions, click the Save button to continue with the next element.

7. After all the claims have been substantiated and the substantiations saved, the green checkmark will
show on the Status column.

Step 3.1.2.1 Copy Substantiation Answers

Prerequisites: For at least one chemical in your submission, at least one green checkmark is shown in the
Status column.

1. If the chemical or trade product is missing a status icon, click the Copy (paper stack) icon to trigger the
copy functionality.

2. Select a chemical from the dropdown menu from which you wish to copy substantiation answers.

a. If a chemical does not display, it is not eligible to be copied.

3. Once a chemical has been selected, choose one of the following options:

a. Click the Copy Substantiations button to copy all applicable chemical substantiations from the
selected chemical to the chemical or trade product you are editing.

b. Click the Copy Substantiations to All button to copy all applicable chemical substantiations
from the selected chemical to all applicable chemicals or trade products in the form.

i. During the copy process, existing substantiation answers are not overwritten.

c. Click the Cancel button to discard and close the copy functionality.

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Chemical Data Reporting Quick Reference Guide

Create a Primary Form U

Step 4 Review and Submit

Step 4.1 Submitting Official Information

1.	The information has been pre-populated from the Primary Authorized Officials CDX registration. If the
information listed is incorrect, please make the appropriate edits to the Authorized Officials user
information in CDX registration.

2.	Check the CBI checkbox to claim the submitters contact information as confidential.

3.	Check the associated checkbox to confirm your acknowledgement of the legally responsible certification
statement.*

4.	Click the Start Submission Process button to activate the submission process.

Step 4.2 TSCA CBI Certification

1.	Review the TSCA CBI Certification disclaimer and certify that all claims for confidentiality asserted
with this submission are true and correct.

2.	To accept, click the Continue button or click Cancel to return to the Submitting Official Information
page.

Step 4.3 CDR Certification

1.	Review the CDR Certification disclaimer.

2.	To accept, click the I Certify button or click Cancel to return to the Submitting Official Information
page.

Step 4.4 Validation

1. The application performs a validation check on the information provided.

a.	If the form passes the validation check, the CDR Validation window displays with No Errors
Found. Close the window and click the Review & Submit button to proceed to Step 4.5 or click
Cancel to return to the Submitting Official Information page.

b.	If the form fails the validation check, the CDR Validation window displays with the identified
errors.

c.	Review the identified errors and click the error hyperlink to navigate to the appropriate page and
correct.

d.	Click the Validate link again to re-validate a form.

Step 4.5 PDF Generation

1.	The form automatically generates a PDF format of the CDR Electronic Reporting form. If your form
contains more than 20 chemicals, a separate PDF will be generated for each 20 chemicals. Therefore, a
form with 30 chemicals will generate 2 PDFs and a form with 105 chemicals will generate 6 PDFs.

2.	Click the Download button to download a copy of an individual PDF.

a. The form automatically generates a PDF format of the CDR Electronic Reporting form. If your
form contains more than 20 chemicals, a separate PDF will be generated for each 20 chemicals.
Therefore, a form with 30 chemicals will generate 2 PDFs and a form with 105 chemicals will
generate 6 PDFs.

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© 2020 CGI Federal
EPA TO 47QFCA-18-F-0009

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Chemical Data Reporting Quick Reference Guide

Create a Primary Form U

3. Click the Sign, Encrypt, and Submit button to complete the submission process in Step 4.6 or click
Cancel to return to the Chemical Summary page.

Step 4.6 CROMERR Signature

1.	Click the Accept button on the pop-up window that reads: "I certify, under penalty of law that the
information provided in this document is, to the best of my knowledge and belief, true, accurate, and
complete. I am aware that there are significant penalties for submitting false information, including the
possibility offines and imprisonment for blowing violations. "

2.	Enter the CDX password and click the Login button.

3.	Enter the answer to the Verification question and click the Answer button.

4.	Click the Sign button.

5.	Click the Home button to return to the Home page or Logout to leave the application.

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© 2020 CGI Federal
EPA TO 47QFCA-18-F-0009

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